Category: Base Erosion & Profit Shifting

British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the...

eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The...

The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international...

The European Union has accused Ireland of swerving international tax rules by letting Apple shelter profits worth tens of billions of dollars from revenue collectors in return for maintaining jobs. European Competition Commissioner Joaquin Almunia told the Dublin government in a letter published on Tuesday that tax deals agreed in...

Inland Revenue has gone shopping for a database to help it fight erosion of the tax base and “profit stripping” by multinational corporations. The database will help the taxman to independently assess the level of profitability companies should be returning for tax purposes by benchmarking the prices multinationals charge their...

There is nothing illegal about tax planning. Yet some things are legal while others are not, and the lines can sometimes get fuzzy. Add to that the fact that some people go to extraordinary lengths to avoid paying taxes, and it can be a recipe for disaster. Increasingly, if you...

The fund management industry could be exempted from new global rules intended to combat tax avoidance by multinational companies if further work finds that they may “hamper legitimate transactions”, according to the Office for Economic Cooperation and Development (OECD).26 Sep 2014 Corporate Tax Corporate tax Tax Disputes and Investigations Investment...

Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts...

European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were...

Global corporations based in the UK will now have to report where they make their profits and pay their taxes to HMRC, the UK government has announced. The new country-by-country reporting template was released this week by the OECD and the UK is the first of 44 countries to officially sign...

Nokia, Skype and Minecraft-maker Mojang have more in common than just the fact that they are among Microsoft’s biggest acquisition targets in recent years. They are all also based outside the U.S., and that’s no coincidence. As the debate over so-called inversions heats up and critics — from President Obama...

The Organisation for Economic Co-operation and Development (OECD) published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where...

Twitter is funnelling much of the revenue it generates in Britain through an offshore sales structure, newly published annual accounts suggested today. Twitter UK has filed abbreviated 2013 accounts for a small company under Companies House rules, which are usually applicable to a business with an annual turnover of less...

The Organisation for Economic Co-operation and Development (OECD) published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where...

The Chartered Institute of Taxation’s Tax Policy Director has said the “first wave of reports [from the Organization for Economic Cooperation and Development on base erosion and profit shifting] is a significant step forward in the process of modernizing the international tax system, but the test will be getting international...

Reports that Lonmin was evading tax were denied by a spokeswoman on Monday, after calls that the company should be investigated. “It is completely false, we are busy preparing a statement,” spokeswoman Sue Vey said. Vey said she was not sure when the statement would be released. Earlier, Sars spokesman...

The beautiful part is the administration did it without Congress. Jared Bernstein, a former chief economist to Vice President Biden, is a senior fellow at the Center on Budget and Policy Priorities and author of “Crunch: Why Do I Feel So Squeezed?” among other books. Well, would you look at...

Plans to curb tax avoidance will hit Ireland. Most countries are set to force multinationals to pay more tax and as the political controversy grows, our own role in these activities will come under ever increasing scrutiny On Tuesday the OECD, the Paris-based club of the world’s richest economies, published...

The finance ministers of the G20 nations on Saturday resolved to tackle Base Erosion and Profit Shifting (BEPS) to make sure companies pay their fair share of tax. “We have also agreed to increase transparency and crack down on tax evasion,” said an official statement after the first day of...

The German-Irish Chamber of Commerce is based in discreet but elegant offices on Fitzwilliam Square in Dublin. It has a much lower profile than the American Irish Chamber of Commerce, but in many ways it is just as important. Ties with the US are hugely important for obvious reasons. There...

POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)....

Having recently blasted corporate tax evaders, the deputy president now has egg on his face after Lonmin’s Bermuda tax avoidance tactics surfaced. Evidence before the Marikana commission that Lonmin moved millions in platinum revenue from South Africa to tax-free Bermuda is likely to prove embarrassing for ANC deputy president Cyril...

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS). These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant...

The OECD wants to force businesses to declare their turnover and number of employees in each country where they are active. Among the multinationals targeted are digital giants Google, Apple and Amazon. The Organisation for Economic Co-operation and Development (OECD) has announced an international action plan called “Project BEPS”, to target...

THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have...

HONG KONG – The government of Hong Kong has recently announced that it will support the Organization for Economic Cooperation and Development’s (OECD) new global standards on the automatic exchange of information for the purpose of enhancing tax transparency and combating cross-border tax evasion. Earlier this year, the OECD released...

Luxury brand came under investigation after routing €680m through its Irish unit Apple and Google are names regularly cited when it comes to using Ireland for aggressive tax planning, but the practice is open to a much wider range of businesses. Bulgari, the Italian jewellery giant whose products were made...

The Organization for Economic Cooperation and Development has released its first set of recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project. The OECD and the Group of 20 finance ministers hope to create a single set...

The Organization for Economic Cooperation and Development recommended Tuesday changes to international tax rules that could stop U.S. multinationals from shifting revenues and profits overseas. A total of 44 large economies, including the U.S., China and Japan, agreed with the new guidelines, but each country must change their laws and may not...

The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is...

A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments...

While Senate Democrats continue to examine specific legislative proposals to deter US multinationals from using corporate inversions to move their tax residence abroad, Republicans remain insistent that any specific anti-inversion legislation should be explicitly linked to comprehensive tax reform. A new bill has been put forward by Charles Schumer (D...

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),...

Australians are increasingly concerned about corporate tax avoidance and support greater measures to tackle profit shifting, a survey shows. Voters are also more likely to view companies such as Apple negatively because of their use of offshore tax havens, and want companies to be required to report their profits and...

American taxpayers are being robbed by yet another giant corporation that is deserting the USA after using the country’s advantages to build untold wealth. Burger King’s recent decision to pursue a corporate inversion to Canada is the culmination of years of maneuvering to dodge paying its fair share in corporate...

Labor has accused the government of procrastinating on a key measure to stop multinational companies shifting profits offshore. It comes as the government prepares to chair the G20 finance ministers meeting in Cairns next week. The information-sharing deal, part of the global push to tackle tax avoidance, has been signed...

The past few years have seen a quantum leap in globalisation, resulting in free movement of capital and labour, shifting of manufacturing bases from high-cost to low-cost locations, gradual removal of trade barriers, technological and telecommunication developments, etc. These developments have, on one hand, led to increasing sophistication in tax...

Financial institutions outside Switzerland may be tempted to think that the U.S. Department of Justice’s focus and pressure on Swiss banks in recent years leaves them in the clear. And, indeed, the DOJ has had great success in targeting these institutions far from U.S. shores. It has levied monetary penalties...

Rep. Mark Pocan, D-Wis., has introduced three pieces of legislation to close tax breaks that enable U.S. multinational corporations to use so-called “inversions” in which they merge with a foreign company and move their tax domicile abroad to a low-tax country to reduce corporate taxes. Corporate inversions are used by...

MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings...

Antony Ting describes it as “like finding treasure”. It was 18 months ago when the powerful US congressional committee blew the lid on Apple’s aggressive corporate tax structure, which allowed it to funnel $US44 billion dollars out of the countrythrough a network of tax haven subsidiaries. Dr Ting, a senior...

Pascal Saint-Amans, the Director of the Organisation for Economic Co-operation and Development’s (OECD’s) Center for Tax Policy and Administration, has visited Liechtenstein to discuss tax matters with Mauro Pedrazzini, Liechtenstein’s Minister of Social Affairs. Among other things, Saint-Amans’s visit focused on the adoption of automatic information exchange in tax matters...

To ensure location-based profits stay on shore. Treasurer Joe Hockey has promised to direct the Tax Office to target multinational businesses who charge Australians more for technology and ship the profits offshore to avoid tax. In a pre-G20 speech this morning, Hockey outlined the ways the Government plans to tighten...

Multinational corporations that use complicated schemes to avoid paying tax in Australia are set to be targeted, with Treasurer Joe Hockey demanding the Commissioner of Taxation “double his efforts”. Mr Hockey has also warned Australians with offshore investments to once again disclose their unreported foreign income to tax authorities before...

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten...

Cape Town – Tax evasion is not only a crime against the state, it is also a crime against the people of South Africa, says Deputy President Cyril Ramaphosa. Ramaphosa has now called on South Africans who are aware of tax evasion by individuals or companies to report them to...

I n July, the American pharmaceutical giant AbbVie, maker of the world’s top-selling drug – the arthritis treatment Humira – reached a blockbuster deal to acquire European rival Shire, best known for the attention-deficit medication Adderall. The merger was cheered by Wall Street, not for what the deal will do...

Twitter is the latest major internet multinational to have opened up a Spanish subsidiary. But the popular micro-blogging site has followed in the footsteps of Google, Apple, Facebook and Linkedin, all of whom keep their Spanish corporate taxes down to the bare minimum by shifting their income to Ireland. Created...

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If...

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint. That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system. The OECD released its Action Plan Addressing...